Privacy Policy

Effective date: October 13, 2026 · Last updated: October 13, 2026

Contents

1. Who we are
2. Scope of this policy
3. Information we collect
4. How we use information
5. How we disclose information
6. No sale, sharing or targeted advertising
7. Cookies, Do Not Track and Global Privacy Control
8. How long we keep information
9. Marketing emails and your choices
10. Your US state privacy rights
11. Additional information for California residents
12. Children's privacy
13. International transfers and UK/EEA visitors
14. Security
15. Changes to this policy
16. Contact us

1. Who we are

SecondSim is a trading name of Serious People Ltd, a private limited company registered in England and Wales (Company No. 16018972) with its registered office at 3rd Floor, 86–90 Paul Street, London EC2A 4NE, United Kingdom ("SecondSim", "we", "us" or "our").

Serious People Ltd is the business responsible for (the "controller" of) the personal information described in this policy.

2. Scope of this policy

This policy applies to personal information we collect through getsecondsim.com (the "Site"), including the US launch waitlist, and through emails we send about the US launch.

SecondSim's US mobile service is not yet available. Before we start selling the service in the US, we will update this policy to cover account, billing, eSIM provisioning and customer-support information, and we will tell waitlist members about the update. Our UK service at secondsim.co.uk is covered by its own privacy policy.

3. Information we collect

Information you give us

• Contact details: the email address you enter in the waitlist form.
• Plan interest: if you click a plan before joining, we record which plan (Flex, 3-Month or Annual) so we can send you relevant launch information.
• Correspondence: anything you choose to send us if you email us, such as your name and the content of your message.

Information collected automatically

• Technical and log data: when you visit the Site, our hosting provider automatically receives standard request information such as your IP address, browser type, device type, the page requested, the referring page and the date and time of the request.
• Security data: when you submit the waitlist form, we use your IP address briefly, in memory, to limit repeated submissions and prevent spam. We do not store it with your email address.
• Email engagement data: our email provider may record whether launch emails were delivered, and whether they were opened or links were clicked.
• Analytics data (only with your consent): if you accept analytics cookies, Google Analytics collects information about how you use the Site, such as pages viewed, time on page, approximate location (derived from your IP address), device and browser type, and how you arrived at the Site. See section 7.

Information we do not collect

Through the Site we do not ask for or collect payment card details, government ID numbers, precise geolocation, phone call or text content, or any other "sensitive personal information" as defined by US state privacy laws.

4. How we use information

• To add you to the US waitlist and email you about the launch of SecondSim in the US, including your early-access offer.
• To understand which plans waitlist members are interested in, so we can plan the launch.
• To respond to your questions and requests.
• To operate, secure and maintain the Site, including detecting and preventing spam, fraud and abuse.
• If you consent, to measure how the Site is used so we can improve it.
• To comply with legal obligations and to establish, exercise or defend legal claims.

We do not use your information for automated decision-making that produces legal or similarly significant effects.

5. How we disclose information

We disclose personal information only to the following categories of recipients, and only for the purposes described in this policy:

• Service providers (processors) that act on our behalf under written contracts restricting their use of the information, including:
  • Vercel Inc. (website hosting and server functions; receives technical and log data);
  • Resend (email delivery and waitlist storage; receives your email address and plan interest);
  • Google LLC (Google Fonts, where your browser requests font files directly from Google, which receives your IP address and browser information; and, only if you accept analytics cookies, Google Analytics, which receives the analytics data described in section 3).
• Professional advisers such as lawyers and accountants, where needed.
• Authorities and others where we are required to by law, or where necessary to protect the rights, property or safety of SecondSim, our users or the public.
• Business transfers: a buyer, successor or investor in connection with a merger, acquisition, financing or sale of all or part of our business, subject to this policy.

6. No sale, sharing or targeted advertising

We do not sell personal information, and we have not sold personal information in the past 12 months. We do not share personal information for cross-context behavioral advertising, do not process it for targeted advertising, and do not use it for profiling in furtherance of decisions that produce legal or similarly significant effects. We do not knowingly sell or share the personal information of consumers under 16.

We do not disclose personal information to third parties for their own direct marketing purposes (California Civil Code § 1798.83, "Shine the Light").

7. Cookies, Do Not Track and Global Privacy Control

The Site does not set advertising cookies and does not use tracking pixels, session-replay tools or similar technologies.

Analytics cookies (optional): with your permission, we use Google Analytics to understand how visitors use the Site. Google Analytics does not load, and sets no cookies, unless you click “Accept” in our cookie banner. If you accept, it sets these first-party cookies:

• _ga: distinguishes visitors; expires after 2 years.
• _ga_G2BEJ4Y2K0: keeps track of your session; expires after 2 years.

We do not use Google Analytics advertising features, and we do not use it to identify you personally. We store your choice in your browser's local storage (ss_cookie_consent) so we don't ask you on every visit. You can change your mind at any time using the Cookie settings link in the footer. Declining removes Google Analytics cookies from this Site. You can also block cookies in your browser settings or install the Google Analytics opt-out add-on.

Do Not Track: because we do not track visitors across third-party websites over time, the Site does not change its behavior in response to browser "Do Not Track" signals.

Global Privacy Control (GPC): we do not sell or share personal information. If your browser sends a GPC signal, we treat it as a choice to decline analytics cookies and do not show the cookie banner, unless you later choose to accept through Cookie settings. We also treat a GPC signal as a valid request to opt out of any sale, sharing or targeted advertising, now and in the future.

8. How long we keep information

• Waitlist information: until you unsubscribe or ask us to delete it, or until 24 months after the US launch, whichever happens first.
• Technical and log data: kept by our hosting provider for a limited period (typically days to a few weeks) for security and operational purposes.
• Rate-limiting data: held in temporary memory for about one minute.
• Analytics data (if you consent): retained by Google Analytics for 14 months, then deleted.
• Correspondence: for as long as needed to deal with your request, and then for up to 24 months unless a longer period is required by law.

When you unsubscribe, we may keep your email address on a suppression list solely to make sure we don't email you again.

9. Marketing emails and your choices

By joining the waitlist, you ask us to email you about the SecondSim US launch. Every email includes an unsubscribe link, and we honor unsubscribe requests promptly, in line with the CAN-SPAM Act. You can also unsubscribe by emailing support@secondsim.co.uk. We will not send you text messages or calls based on the waitlist.

10. Your US state privacy rights

Depending on where you live, laws such as the California Consumer Privacy Act (as amended by the CPRA) and the consumer privacy laws of states including Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah and Virginia may give you some or all of these rights:

• Know and access: confirm whether we process your personal information and get a copy of it, including the categories of information, sources, purposes and recipients.
• Correct: ask us to correct inaccurate personal information.
• Delete: ask us to delete personal information we hold about you.
• Portability: receive your information in a portable, commonly used format.
• Opt out: of the sale or sharing of personal information, targeted advertising and certain profiling. (We don't do any of these.)
• Limit use of sensitive personal information. (We don't collect any through the Site.)
• Non-discrimination: we will not deny you service, charge you a different price or give you a different level of service for exercising your rights.

Whether or not a particular state law applies to us, we will honor these requests from any US resident.

How to make a request

Email support@secondsim.co.uk with the subject line "US privacy request", and tell us which right you want to exercise and the email address you used on the Site.

Verification: to protect your information, we will verify your request, usually by asking you to confirm it from the email address we hold. We only use the information you give us for verification to verify and process your request.

Authorized agents: you may use an authorized agent to make a request for you. We may ask for signed written permission from you, and ask you to verify your identity directly with us, unless the agent has a valid power of attorney.

Timing: we will confirm receipt within 10 business days and respond within 45 days. If we need more time (up to an additional 45 days), we will tell you why.

Appeals: if we decline your request, you may appeal by replying to our decision with the subject line "Privacy appeal". We will respond to your appeal within the time required by your state's law (generally 45 to 60 days). If you are not satisfied with the outcome, you may contact your state Attorney General.

11. Additional information for California residents

This section serves as our notice at collection and describes the personal information we have collected in the past 12 months, using the categories defined in the CCPA.

Retention periods for each category are set out in section 8. We do not offer financial incentives in exchange for personal information. The early-access discount is offered to everyone on the waitlist and is not tied to the value of your data.

Nevada residents: we do not sell covered information as defined in Nevada law. You can still send an opt-out request to support@secondsim.co.uk.

12. Children's privacy

The Site and SecondSim's services are intended for adults and businesses. They are not directed at children under 13, and we do not knowingly collect personal information from children under 13 (or under 16 where state law requires). If you believe a child has given us personal information, contact us and we will delete it.

13. International transfers and UK/EEA visitors

Serious People Ltd is based in the United Kingdom, and our service providers may process information in the United States, the United Kingdom and other countries. Wherever your information is processed, we protect it as described in this policy.

If you are in the UK or European Economic Area, UK GDPR or EU GDPR also applies. We rely on your consent to send launch emails and to use analytics cookies (both of which you can withdraw at any time), and on our legitimate interests to operate and secure the Site. Where your information is transferred outside the UK or EEA, we use recognized safeguards such as the UK International Data Transfer Addendum, the EU Standard Contractual Clauses or the UK-US Data Bridge. You also have the right to object to processing and to complain to the UK Information Commissioner's Office (ico.org.uk) or your local data protection authority.

14. Security

We use reasonable administrative, technical and physical safeguards to protect personal information. These include encrypted (HTTPS) connections, restricted access to waitlist data, origin checks and rate limiting on our form, and contracts with our service providers. No method of transmission or storage is completely secure, but we work to protect your information and will notify you and the authorities of a data breach where the law requires.

15. Changes to this policy

We may update this policy from time to time, including when the US service launches. We will post the updated version on this page with a new "Last updated" date. If we make material changes, we will notify waitlist members by email before the changes take effect.

16. Contact us

If you have questions about this policy or want to exercise your privacy rights, contact us: